Document k6grmk7xQaR1y4BRwM48gQLeB

Hypothetical Use Cases to illustrate Jurisdiction, Possession, Legal Liability, and need for OSE Permit/Water right Sierra Club v. EPA 18cv3472 NDCA Tier 10 ED 002061 00095659-00001 Sierra Club v. EPA 18cv3472 NDCA Tier 10 ED 002061 00095659-00002 J = OCD PO = Producer* L = Treatment Co. P = Yes RE = Yes J = OCD for disposition NMED for final use PO = User/Purchaser L = User/Purchaser P = per NMED J = OCD PO = Producer J = OCD PO = Producer RE = No PR = No L = Producer P = No L = Transport Co. P = Yes Waste Disposal RE = Yes RE = No J = OCD PO = Producer* L = Treatment Co. P = Yes Key: RE = Yes Jurisdiction= J Possession = PO Legal Liability = L Permit = P Reporting = RE Permit+Right = PR (OSE only) Hypothetical Case for Reuse outside of Oil and Gas Industry Closed-Loop system, no discharge to Waters of the State * Unless sold/transferred by contract Full consumption of a clean water product Sierra Club v. EPA 18cv3472 NDCA Tier 10 ED 002061 00095659-00003 J = OCD PO = Producer* L = Treatment Co. P = Yes RE = Yes J = NMED/EPA PO = User/Public Entity [ L = User/Public Entity P = yes (NPDES) RE = yes (NMED) J = OCD J = OCD PR = No PO = Producer PO = Producer L = Producer P = No L = Transport Co. P = Yes Waste Disposal RE = Yes RE = No J = OCD PO = Producer* L = Treatment Co. P = Yes Key: RE = Yes Jurisdiction= J Possession = PO Legal Liability = L Permit = P Reporting = RE Permit+Right = PR (OSE only) * Unless sold/transferred by contract Hypothetical Case for Reuse outside of Oil and Gas Industry Partial or no consumption of clean water product Possible discharge to Waters of the State/Navigable Waters Sierra Club v. EPA 18cv3472 NDCA Tier 10 ED 002061 00095659-00004